Elemental

CLG have just issued research (by Arup): …to examine the implementation of the Planning Policy Statement (PPS) on Climate Change, particularly through the take up of its policies in regional spatial strategies and local development plan documents, and their application through development control. It also identifies any barriers to effective implementation of the policies in the PPS on Climate Change.

I haven’t seen much fanfare in the press about this, so a quick summary blog post is in order. The findings should be of interest to anyone who writes sustainability or energy statements for planning (such as myself). Those who do will be painfully aware of the variances between authorities. This report supports that experience and suggests reasons why this is the case.

I’ve cheated and only read the conclusions and dipped back into the body of the report when I’ve found something of interest (it’s a 196 page pdf!). The highlights are below:

• The two principal aims of this study were to examine the implementation of climate change PPS policies through take up of its policies in regional spatial strategies and local development documents and their application through development control; and also to identify any barriers to effective implementation of the policies of the climate change PPS.
• The existence of SPD policy reduces (on occasion) a local authority’s priority to address the same issue (such as renewable energy) in detail in their core strategy; and this can create risk and confusion for developers.
• Just under half the respondent authorities have such energy assessments in place but others are about to commission them. Together this represents 62 per cent of respondent authorities.
• Key barrier to prioritising, carrying out and using feasibility assessments – Lack of any standardised methodology or clear advice in relation to the preparation of such assessments and debate regarding the importance of (and how to) consider financial viability.
• Limited reference in RSS and core strategy visions to: achieving zero carbon in all new development; creating an attractive environment for innovation and investment in climate change technologies; and capturing local enthusiasm.
• Perception that national zero carbon target is over ambitious particularly in heavily built up areas.
• For some authorities a lack of understanding regarding the basics of climate change terminology, e.g. the difference between zero carbon and carbon neutral.
• Least frequent consideration is given to the potential feasibility of decentralised and renewable or low carbon energy, and the ability to build and sustain socially cohesive communities.
• Lack of clarity about the concept of building and sustaining socially cohesive communities might influence the land selection process.
• Availability of low carbon and renewable energy resources were rarely used as criteria when selecting areas for development.
• Perception of most regional authorities that identification of opportunities for decentralised renewable and low carbon energy could not easily be done at the regional scale.
• While some authorities have identified specific areas of land as suitable for renewable or low carbon energy sources, this practice is not yet widespread.
• A significant proportion of local authorities claim to have policies promoting renewable and low carbon energy generation and supporting infrastructure, but many relate solely to targets for supply to new development.
• Sustainable buildings policy is less evident, with some local authorities suggesting that there is little to add to regional policies.
• A lack of clarity regarding the policy requirement to promote decentralised, renewable and low carbon energy generation and the appropriate means to do this.
• Targets relating to the supply of energy to new developments are being set in just over half emerging core strategies. Differentiated targets are less common, even in authorities where feasibility assessments have been undertaken.
• There are inconsistent approaches to the scope and phrasing of energy supply targets (and also in relation to calculations regarding anticipated energy use).
• Grouping of decentralised, renewable and low carbon energy together considered to be unhelpful due to their differing costs.
• The need for a clearer inter-relationship between planning and building regulations, with a more strategic approach to land use planning.
• Belief amongst some councils that viability testing of an energy supply target of 10 per cent is unnecessary because the use of such a target is widespread.
• Nearly two thirds of authorities require information relating to climate change and sustainability through design and access statements or other sustainability assessments. Some request renewable energy statements.
• Level of training and awareness amongst local authority planners and councillors in relation to climate change issues is proving to be a significant barrier. This includes a widespread lack of access to technical expertise.
• Perceived conflicts with PPS22 and PPS3.

There are many, many more barriers and findings in the main report. Suffice to say, the conclusions are that the waters are generally very muddy. It’s good to see evidence that vindicates my personal experience between planners – now we just need to work out how to get ourselves out of this pickle! Some of the recommendations Arup suggest are:

Carbon reduction target instead of energy supply target. Consideration could be given to providing a greater linkage between planning policy and the national climate change agenda by replacing the PPS requirement for DPDs to set energy supply targets, with a requirement for the setting of carbon emissions reduction targets for new development. At regional level, the carbon reduction target could be apportioned sub-regionally, in the context of opportunities and scale of development in different districts. Local ‘carbon reduction target’ policy would require the reduction of emissions of the planned development from nationally agreed levels normally associated with a building/development of its type. This would provide a clearer relationship between the LDF and local authority performance targets and from these to regional targets and ultimately to national targets. It also provides greater simplicity for local authorities who already measure carbon emissions.

Consistency in target wording and calculations. Consideration could be given to an appropriate means of achieving consistency across the country in relation to the wording of targets (and the calculations associated with them), in order to ease the process of implementation by developers.

Scope of feasibility assessments. The PPS could clarify the range of uses for which feasibility assessments are required, including the process of land selection at both:

• the strategic (core strategy) level, in relation to, for instance, identifying areas for sustainable urban extensions and also

• a finer grain level in land allocations DPDs.

It could also include greater clarity on the intended scope of the assessments i.e. to include consideration of financial viability and to clarify the role that heat mapping can play. Reference should also be included to a standard methodology in Practice Guidance, a proposal widely supported by developers and consultants in preference to a series of separate good practice examples.

Training in energy planning. There are likely to be advantages in:

• Training for plan makers, in order for authorities to recognise the limitations of their knowledge and experience and enable them to seek appropriate advice regarding feasibility assessments. This should include clarification of climate change terminology.

• Training for development managers in order that they can understand and interrogate technical information appropriately.

• Training for council members in the field of strategic energy planning and its potential advantages for local authorities in order to increase political awareness.

• Extending training for enforcement officers to include issues related to climate change

• Further training for Inspectors to help ensure greater consistency and confidence in dealing with climate change issues in applications.

Any further thoughts on how we clarify this issue?

admin News planning, PPS

These are my links for October 24th through October 29th:

• Campaign calls for strengthened renewables policy – PlanningResource – "Ministers pledged in July to update the guidance in PPS1 and PPS22 to "ensure that they set a clear and challenging framework for delivering energy infrastructure consistent with national ambitions."
  TCPA energy policy manager Kate Henderson said: "The planning system can play a key part in tackling climate change by ensuring we get the right amount of renewable energy, by encouraging carbon zero development and by shaping development which reduces the need to travel by car.
  "But despite some excellent rhetoric, much of the planning system is still locked in the age of stupid. It allows carbon intensive development and often refuses real solutions to climate change such as renewable energy projects."
  Ministers plan to publish a draft new PPS on climate change and renewable energy by the end of the year, with the aim of adopting new guidance before the end of the current parliament."
• Energy standards for homes to fall short of Passivhaus – Building – The death knell for CSH?: "The Hub has proposed a radical overhaul, with builders asked to meet an annual energy output per square metre depending on building type, rather than satisfy the points-based system operated by the code."
• UK must replace 12 million non-condensing boilers by 2022 says CCC – CCC recommends that: "Non-residential buildings achieve a minimum Energy Performance Certificate rating of F or higher by 2020."
• SuperFreakonomics Ignores the Business Case for Sustainability – Andrew Winston – HarvardBusiness.org – I have largely missed the Superfreakonomics geo-engineering debate – this is a good starting point. Hoping to catch Levitt and Dubner at LSE later this month – some pointed questions will be ready…
• Statistics watchdog hits out at government emissions claim – PlanningResource – "The government has been exaggerating the UK's success in cutting carbon emissions, according to the UK Statistics Authority.A Department of Energy and Climate Change claim that carbon emissions were 12.8 per cent lower in 2007 than in 1990 is "unsatisfactory" and falls short of the government's code of practice for official statistics, said the watchdog's chairman Sir Michael Scholar.In a letter to the Commons environmental audit committee chairman Tim Yeo, he said nearly a third of that fall is made up of carbon credits in the EU trading scheme and do not represent real
  cuts. The fall is 8.5 per cent without the credits."
• RIBA to bin ‘outdated’ fee scale graphs | News | Architects Journal – So everyone will be laminating their old copy then? : "The RIBA is to drop its fee scale graphs in the latest edition of A Clients Guide to Engaging an Architect.
  The loss of the graphs, which featured percentage fees based on independent cost survey data, marks the demise of the institutes once compulsory fee scales abolished as mandatory in 1982 and as recommended scales in 1992.
  The RIBA maintained the revised guide would still contain concise written advice about how practices calculate fees and structure payment options."
• PassivHaus UK – My current obsession with U-values unearthed this gem: "Please note that whilst PHPP includes a worksheet for calculating the U-values of components it is not sufficiently accurate for demonstrating compliance against UK building regulations as it does not adhere to BRE document Conventions for U-value calculations (2006 Edition). Whilst the U-value calculator incorporated within PHPP is used as a basis for certification purposes designers are recommended to use suitable U-value calculator software packages for demonstrating UK building regulations compliance and undertaking SAP calculations, suitable software includes BRE's own U-value calculator, or other software packages such as BuildDesks free U-value calculator."
• Climate Change (Political Response): 21 Oct 2009: House of Commons debates (TheyWorkForYou.com) – Andrew Stunell (Lib Dem) reminds us all of a forgotten Bill during last week's 1010 debate: "In 2004, I was fortunate to be top of the ballot and able to introduce the Sustainable and Secure Buildings Bill in this House. I wish to say to the House and to the Minister that there have been missed opportunities as a consequence of the Government not choosing to implement what was in that Bill, which allowed them to amend the building regulations to take account of the sustainability and efficiency of buildings."
  Worth reading the entire debate (despite the outcome)

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I know I said I had gone for Xmas, but a quick comment on the supplement to PPS1:

para.  20:

In particular, planning authorities should:
– not require applicants for energy development to demonstrate either the overall need for renewable energy and its distribution, nor question the energy justification for why a proposal for such development must be sited in a particular location;
– ensure any local approach to protecting landscape and townscape is consistent with PPS22 and does not preclude the supply of any type of renewable energy other than in the most exceptional circumstances;
– alongside any criteria-based policy developed in line with PPS22, consider identifying suitable areas for renewable and low-carbon energy sources, and supporting infrastructure, where this would help secure the development of such sources, but in doing so take care to avoid stifling innovation including by rejecting proposals solely because they are outside areas identified for energy generation; and

- expect a proportion of the energy supply of new development to be secured from decentralised and renewable or low-carbon energy sources.

Now read that again with the mindset that regulation exists to form boundaries.  Is it just me, or is this giving permission to innovate (which surely does not need to be given).  An awkward way of saying things, in my opinion – being specifically told what we don’t have to prove…

mel starrs Opinion Climate Change, energy development, energy generation, energy justification, energy supply, low-carbon energy sources, PPS, renewable energy